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CSR Policy


This CSR Policy encompasses CDE Asia Limited (CDE) responsibilities and lays down the guidelines and mechanism for undertaking projects, programs and activities towards such responsibilities.


The CSR Policy sets out CDE’s commitment towards ensuring that the activities extend beyond business and include initiatives and endeavours for the benefit and development of the community and society. The CSR Policy lays down guidelines for undertaking programmes geared towards social welfare activities or initiatives. Through this CSR Policy, CDE proposes to adopt the CSR Activities mentioned here in.

CDE, through the CSR Activities, will endeavor to enhance value creation in the society and in the community, through its services, conduct and initiatives to promote sustained growth for the society and community, in fulfilment of its role as a socially responsible corporate.

This CSR Policy is in accordance with the applicable provisions of the Companies Act 2013 and the rules issued thereunder.

The objective of the CSR Policy is to:

  • Provide approach & direction including guiding principle for selection, implementation & monitoring of CSR activities
  • Formulation of Annual Action plan
  • Outline projects, programs and activities to be undertaken by CDE
  • Specify the modalities of execution of such projects, programs and activities
  • Monitor the process to be followed for such projects, programs and activities
  • Generate goodwill for Responsibility initiatives at CDE and help reinforce a positive and socially responsible image, through CSR Activities


The CSR Committee has been constituted in accordance with the provisions of the Act comprising of the following Directors. These are:

  • Mr. Manish Bhartia - Chairman
  • Mr. Raja Venkatraman - Member
  • Mr. Enda Ivan off - Member

The Company Secretary shall be the secretary to the Committee. The CSR Committee may invite other experts/ invitees as per its requirements.

CSR Committee shall be responsible for:

  • Formulating, monitoring and recommending to the Board the CSR Policy any subsequent change/ modifications there to
  • Recommending the amount to be spent and their budgets as well as recommendation of any subsequent change/ modification there to
  • Institute an implementation and monitoring mechanism for CSR Activities
  • Periodically updating the Board on the progress being made in the planned CSR Activities
  • Providing an Annual Action plan to the Board


The CSR Cell has been constituted to assist the CSR Committee with the implementation and impact assessment of the CSR initiatives. The CSR Cell comprises of the following:

  • Mr. Sanjay Kumar Singh
  • Mr. Manish Madhogaria
  • Mrs. Anshumita Sengupta

The CSR Cell shall be responsible for:

  • Identifying CSR Activities at the directions of the Board and the CSR Committee
  • Undertaking impact assessment of the CSR Activities
  • Determining the modalities of execution including targets and timelines in consultation with the CSR Committee
  • Timely implementation of the CSR Activities approved by the Board in compliance with the applicable provisions of the Act and CSR Rules
  • Providing periodic reports to the CSR Committee on implementation as well as assessment carried out through field visits and feedback sessions and
  • Any other assistance as may be required by the Board and the CSR Committee in relation to implementation of the CSR Activities


CDE has identified the following focus areas of intervention:

  • Education
  • Livelihood and Employment enhancement
  • Hunger, Poverty & Malnutrition
  • Environment sustainability
  • Relief & Rehabilitation
  • Technology Incubators

CDE may undertake the CSR Activities either itself or through other qualifying Non-government organizations (“NGOs”) or agencies. The projects, programs or activities identified by the CSR Committee and approved by the Board shall be implemented in a project mode through the CSR Cell which will entail charting the stages of execution through planned processes, measurable targets, mobilization and allocation of budgets and prescribed timelines. It also involves assigning of responsibility and accountability. Suitable documents / agreements shall be entered into with NGOs and the other agencies for the purposes of implementation of the CSR Activity, in case the CSR Activity is proposed to be implemented through the third party agencies. The conditions of grant of amounts for all CSR Activities and the break-up of the allocations shall be set out and evaluated from time to time.

To the extent feasible, a project based accountability approach to stress on the long term sustainability of CSR Activities shall be adopted, and the indicative action plan and implementation schedule (timelines) for the projects, programs and activities shall be adopted.

The Board shall ensure that appropriate designated staff or personnel provides adequate assistance to the CSR Committee to enable it to make necessary recommendations to the Board. For this purpose, the CSR Committee may also approach external consultants for necessary assistance as it may deem fit.

The CSR Cell shall undertake sufficient due diligence of each of the NGOs before engaging for any implementation.

Based on the recommendations of the CSR Committee, the Board shall approve the following:

  • Approve the CSR policy and amendments, if any
  • The specific CSR Activities that should be undertaken from time to time
  • Whether the CSR Activities will be undertaken directly or through an implementing agency or in collaboration with any other companies, including by availing services of any NGOs
  • Approve the Annual CSR Report
  • Approve the disclosures in the Annual Directors report
  • Approve the Disclosures in Company website

Activities undertaken in pursuance of the normal course of CDE’s business shall not be considered towards CSR Expenditure.


The minimum CSR spend by shall be as per the requirements of the Companies Act 2013. The Board shall approve the allocation of the CSR Expenditure on the CSR Activities and, to the extent possible, shall give priority to:

  • Programs within the local areas wherever CDE has its operations
  • Respect & promote Human Rights
  • Respect, protect & make efforts towards environment sustainability
  • Enhance income generation capability to the beneficiaries

At the minimum, the CSR program should incorporate at least one of the above-mentioned elements.

On the basis of identified CSR activities / projects, the Annual CSR Plan shall be prepared by the CSR Cell.

The CFO of the company shall certify that the funds so disbursed for CSR have been utilised for the purposes and in the manner approved.


An Annual action plan will be prepared by the CSR Cell and will include:

  • Approved CSR projects
  • Manner of execution of the projects
  • Modalities of utilisation of funds
  • Implementation schedules
  • Monitoring and reporting mechanism
  • Details of need
  • Impact assessment, if any

The plan shall be prepared before the commencement of the next financial year or latest before the first CSR committee meeting for the financial year.

The CSR Annual Plan may, however, be amended/modified at any time during the financial year by the Board.

The approved CSR Annual Plan shall form part of this policy.


Baseline survey would be conducted by the implementing agency and annual reviews shall be undertaken to ascertain the progress, wherever possible & to the extent feasible.

The Board along with the CSR Committee and the CSR Cell shall be responsible for implementation of this CSR Policy.

By implementing the CSR Activities, CDE expect to make a substantial improvement, over a period of time, in the identified areas.

To the extent feasible, a project based accountability approach to stress on the long term sustainability of CSR Activities shall be adopted, and the indicative action plan and implementation schedule (timelines) for the projects, programs and activities shall be adopted.


To ensure effective implementation of the CSR projects, programmes and activities undertaken in terms of this CSR Policy, the progress of each such project, programme and activity will be reported to the CSR Committee on a quarterly basis, with all requisite documentation.

The CSR Committee may conduct impact studies or on a periodic basis, through independent professional third parties/professional institutions.

The CSR Committee shall also try to obtain feedback, either by itself or by external professional firms, from the beneficiaries of the CSR projects, programmes and activities for providing the required feedback and inputs to formulate and improve the programs in future.


Regular and interactive feedback sessions shall be conducted at all levels including with other NGOs through which CSR Activities are being undertaken as well as the respective beneficiaries of all the CSR Activities undertaken.

Field visits shall be conducted at regular intervals to ensure effective implementation.

Proper documentation shall be done in an MIS format to record key observations of such feedback sessions and field-visits.

If required & deemed necessary by the CSR Committee, the effectiveness of the various programs/ activities undertaken under the CSR Policy may be evaluated through external agencies and impact reports shall be prepared pursuant to such evaluation.


The CSR Committee shall maintain proper minutes of all its meetings.

The CSR Committee shall prepare an annual report on CSR with such information and particulars as may be required by the Act and such report shall be included in the Board’s report annexed to the financial statements.

The Board’s report shall include an annual report on CSR containing such details as may be prescribed from time to time under the Act and the CSR Rules.

The Board will be responsible to ensure that the statutory requirements as may be prescribed from time to time under the Act and the CSR Rules are complied with.


Any surplus arising out of the CSR projects/programs or activities shall not form part of the business profits of CDE.

If it is observed that any CSR Activity taken up for implementation is found not properly implemented, the CSR Committee may, with approval of the Board, may discontinue funding the project at any time during the course of implementation and use such funds for any other project.

The CSR Committee shall have the power to clarify any doubts or rectify any anomalies that may exist in connection with the effective execution of this CSR Policy.


The CSR Committee is empowered to amend or modify the CSR Policy and such changes shall be placed before the Board for its approval. The Board may subject to compliance with applicable law, at any time approve or alter, amend or modify the CSR Policy, as it deems fit to comply with the statutory obligation to undertake the CSR Activities.

This supersedes the CSR Policy Version 1.0 which was approved by the Board on 22.12.2020 through a circular resolution.

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